Interpretation ID: aiam0862

Mr. J. Richard Schlen, Schlen Body and Equipment Co., P. O. Box No. 229, Carllnville(sic), IL 62626; Mr. J. Richard Schlen
Schlen Body and Equipment Co.
P. O. Box No. 229
Carllnville(sic)
IL 62626;

Dear Mr. Schlen: This is in reply to your letter of September 22 to Mr. Ed Leysath o this Office regarding interpretations of FMVSS No. 108 on required mounting of marker lights on your dump trailers.; In answer to your first problem, a combination front clearance and sid marker lamp must meet the requirements for both, therefore, the full 180-degree visibility is required. If you determine that it is not practicable to mount the combination lamp in your alternate location, because of a greater possibility of damage, then separate lamps should be considered.; In answer to your second problem, because of the configuration and en use of your dump semi-trailers, your interpretation that rear clearance lamps mounted in a light box just below the rear trailer crossmember are as high as practicable is correct.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;